Elevated Vue 

490 River Crest Dr N 

Helena, AL 35080 

205.337.8030 

dan@elevatedvue.com 

8 March 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Re: Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 61.113(a) and (b); 

14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a) ; 14 CFR 91.405 (a); 14 CFR 91.407(a)(1); 14 CFR 

91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 

14 CFR Part 11, Elevated Vue hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial use of its Small Unmanned Aircraft Systems (SUASs), so long as 

such operations are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333. 

An exemption is being requested because (1) existing regulations will burden Elevated Vue (2) Elevated 

Vue can provide a level of safety that is equal (or greater than in many cases) to those provided by 

existing rules, and (3) the request is in the public interest. The FAA's authority to issue exemptions from 

operating rules, and the Secretary's authority granted by Section 333 of P.L. 112-95, Special Rules for 

Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain SUAS operations in the 

National Airspace System (NAS) prior to implementation of the SUAS rule. This incremental step will 

allow Elevated Vue to safely and legally enter into the NAS. 

As describe in detail below, the requested exemption would permit Elevated Vue to operate SUASs 

under controlled conditions in airspace that is (1) limited (2) predetermined (3) controlled as to access, 

and (4) would provide safety enhancements to the already safe operations of those aircraft of similar 

size, weight, speed, and operating capability that have been granted entry into the NAS via the rules in 

Academy of Model Aeronautics (AMA) National Aircraft Safety Code. l Approval of this exemption would 

thereby greatly enhance safety and fulfill the Secretary of Transportation's (the Secretary) 

responsibilities to "...establish requirements for the safe operation of such aircraft systems in the 

national airspace system" per Section 333 (c) of the Reform Act. 

1 See the attached "AmaSafetyCode.pdf" document 
Elevated Vue is requesting exemption from the following regulations: 

14 CFR Part 21, Subpart H 

14 CFR 61.23 (a) 

14 CFR 61.113 (a) and (b) 

14 CFR 91.109 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(1) 

14 CFR 91.409 (a)(1) 

14 CFR 91.409 (a)(2) 

14 CFR 91.417 (a) and (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333 (a) 

through (c) of the Reform Act. This law directs the Secretary to consider whether certain unmanned 

aircraft systems may operate safely in the NAS before completion of the rulemaking required under 

Section 332 of the Reform Act. In making this determination, the Secretary is required to determine 

which types of UASs do not create a hazard to users of the NAS, to the public, or pose a threat to 

national security. 

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned aircraft 

system, as a result of its size, weight, speed, operating capability, proximity to airports and populated 

areas, and operation within visual line of sight (VLOS) does not create a hazard to users of the NAS or 

the public or pose a threat to national security, and (2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under 49 USC 44704 is required for the operation of civil 

(non-governmental) UASs. Therefore, if the Secretary determines that such vehicles "may operate 

safely in the national airspace system, the Secretary shall establish reguirementsfor the safe operation 

of such aircraft in the national airspace system". 2 

Z Elevated Vue Interprets this provision to place the dutv on the Secretarvto not only process applications for 

exemptions under Section 333 of the Reform Act, but for the Secretary to craft conditions for safe operations of 

SUAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for 

approval. 
Corporate Overview 

Elevated Vue's SUASs are quadcopters, weighing 6.5 or fewer Ibs. (including payload). The SUASs have 

the capability to hover and move in the vertical and horizontal planes simultaneously. They will operate 

only in visual line of sight (VLOS) and will operate only in tightly controlled and limited airspace. They 

are capable of operating at speeds of up to 43 knots, but will be routinely operated at much lower 

speeds. They will routinely be operated below 200 feet above ground level (AGL), and never above 400 

feet AGL. 

Elevated Vue's exemption request would permit its commercial operation of SUASs for aerial 

photography and videography in tightly controlled and limited airspace. Aerial photography and 

videography services will be offered to private events, homeowners, commercial and personal realtors, 

home builders, home contractors, and/or home inspectors for use in, but not limited to, real estate 

marketing and safer inspections of home exteriors. AII operations will be conducted on private property 

and with the written and/or oral permission of the property owner(s). Operations will always be 

conducted in areas that are clear of all people, except the pilot in command (PIC) and the PIC's helper(s). 

Such operations will ensure that the SUAS will "not create a hazard to users of the national airspace 

system or the public". 3 

Aircraft 

Elevated Vue operates Inspire 14 SUASs manufactured by DJI, a well-known leader in quadcopter 

technology. DJI strives to bring new perspectives to aerial work and help companies accomplish feats 

safer, faster, and with greater efficiency. They have an unparalleled commitment to R&D, a culture of 

constant innovation, and a focus on transforming complex technology into easy-to-use devices. 

The standard Inspire 1 quadcopter package includes the Inspire 1 itself, camera, gimbal, propulsion 

system, flight control system, 5.8 GHz remote controller, and 2.4 GHz communication system. The 

remote uses a 5.8 GHz frequency to prevent interference with the video/telemetry channel. This second 

channel allows for a constant connection with the Inspire 1 to monitor it via a smartphone/tablet that is 

attached to the remote controller. 

The Inspire 1 is about 17.2 inches x 17.7 in. x 11.9 in. in size. It has a maximum ascent speed of 16.4 feet 

per second, a maximum descent speed of 13.1 feet per second, and a maximum flight speed of 43 knots. 

While operating within VLOS, the remote control has a range of approximately 2,600 feet. The total 

weight (including the payload) is 6.4 Ibs. s 

3 Reform Act Section 333 (b) 

4 http://www.dji.com/product/inspire-1 

5 http://store.dji.com/product/inspire-1?position=l#/spec 
The Inspire 1 is equipped with a flight control system that provides incredible ease of use and stability. 

Pilots can control the Inspire 1's movements in many directions — including pitch (forward and 

backward), roll (left and right), elevator (up and down), and yaw (turn left and right). The flight control 

system can also provide intelligent orientation control, failsafe, battery level monitoring (and warnings), 

and show the aircraft's current heading, direction, and approximate distance from home on the onscreen radar. The built-in GPS system aids in stabilizing the aircraft and automatically and safely returns 

it back to its home point in any case where communication between the remote control and quadcopter 

are lost. 

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter that 

measures both attitude (ATTI) and altitude. The IMU incorporates both a 6-axis gyroscope and an 

accelerometer to monitor miniscule changes in tilt and movement. This allows the aircraft to 

compensate and adjust immediately, holding its position at all times. 

The Inspire 1's compass reads geomagnetic information and assist the Global Positioning 

System (GPS) to accurately calculate the position and height of the aircraft. The Inspire 1 also 

has a built in Visual Positioning System (VPS) that allows takeoff and landing at the press of a 

button and keeps the Inspire 1 steady when GPS satellites cannot be required. The system 

combines visual data and sonar waves in a single unit, detecting both variance in patterns on 

the ground and current altitude. Information from the VPS is processed by a dedicated CPU 

chip that takes in feedback and outputs data in real-time, and is intelligent enough to distinguish 

between objects and ground patterns. This data is given to the Inspire 1's flight controller, 

which in turns continues with the entire aircraft. 

The Inspire 1 has LED flight indicators beneath each of its four rotor arms. The LEDs on the 

arms as well as one on the battery, illuminate to indicate the status of the flight control system 

and alert the PIC of any possible issues. Such highly advanced capabilities will ensure that the 

SUASs can be safely operated and "not create a hazard to users of the national airspace 

system or the public." 6 

6Reform Act Section 333 (b) 

4 
Equivalent Level of Safety 

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the 

world and to minimize the risk to the NAS or to persons and property on the ground, Elevated Vue 

agrees to be bound by the following limitations and conditions when conducting commercial operations 

under an FAA issued exemption: 

A. For the purposes of ensuring SUASs will be operated within the standards that the FAA has 

allowed in the AMA Nationa) Model Aircraft Safety Code: 

1. SUASs will not be flown: 

i. In a careless or reckless manner 

ii. At a location where SUAS activities are prohibited 

2. SUAS pilots will 

i. Yield the right of way to all human-carrying aircraft 

ii. See and avoid all aircraft and a spotter must be used when appropriate' 

iii. Not fly higher than 400 feet AGL or within three (3) miles of an airport without 

notifying the airport operator 

iv. Not interfere with operations and traffic patterns at any airport, heliport or 

seaplane base except where there is a mixed use agreement 

v. Not exceed a takeoff weight of 55 pounds (including payload) 

vi. Ensure the aircraft is identified by affixing the owner's contact information to 

the outside of the SUAS 

vii. Not operate SUAS while under the influence of alcohol or while using any drug 

that could adversely affect the PIC's ability to safely control the model 

viii. Not operate SUAS's carrying pyrotechnic devices that explode or burn, or any 

device which propels a projectile or drops any object that creates a hazard to 

persons or property 

3. SUASs will not be flown unless: 

i. The aircraft, control system and pilot skills have successfully demonstrated all 

maneuvers intended or anticipated prior to the specific event 

ii. An inexperienced pilot is assisted by an experienced pilot 

4. AII pilots shall avoid flying directly over unprotected people, vessels, vehicles or 

structures and shall avoid endangerment of life and property of others 

5. A successful radio equipment ground-range check in accordance with manufacturer's 

recommendations will be completed before the first flight of a new or repaired model 

aircraft 

6. SUASs must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC) 

' AMA Document #540-D 

5 
7. SUASs will not knowingly operate within three (3) miles of any pre-existing flying site 

without a frequency-management agreement.8 

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to 

any individual, except for PIC and the PIC's helper(s) located at the takeoff site 

9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still 

under power, except to divert it from striking an individual 

10. The PIC of the SUAS shall: 

i. Maintain control during the entire flight, maintaining visual contact without 

enhancement other than by corrective lenses prescribed for the pilot 

ii. Fly using the assistance of a camera or First-Person (FPV) only in accordance 

with the procedures outlined in AMA Document #550 

iii. Fly using the assistance of autopilot or stabilization system only in accordance 

with the procedures outlined in AMA Document #560 

11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown 

closer than 50 feet to any above-ground electric utility lines 

12. The flying area must be clear before the engine is started, except for PIC and the PIC 

helper(s) 

B. In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in 

an effort to enhance the safety offered by the already safe operations mentioned above, 

Elevated Vue also agrees to be bound by the following limitations and conditions: 

1. Flights will be operated within VLOS of the PIC 

2. Maximum total flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 25 minute limit 

3. The SUAS will only operate in tightly controlled and limited airspace 

4. A briefing will be conducted in regard to the planned SUAS operations prior to each 

flight. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

5. The PIC and the PIC's helper(s) will have been trained in operation of SUAS and received 

up-to-date information on the particular SUAS to be operated 

6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice 

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to 

return to a pre-determined location within the security perimeter and safely land 

8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies 

9. AII flights will be conducted no private property and with the written and/or oral 

permission of the property owner(s) 

10. Flights willalwaysbe conducted in areas that are clear of all people, except for the PIC 

and the PIC's helper(s) 

11. Flights will not be conducted outdoors in visual meteorological conditions (VMC) and 

never during severe weather conditions 

8 AMA Documents #933 and #923 

.1 
12. Flights will not occur in weather conditions that prevent the PIC from operating within 

visual line-of-sight (VLOS) at all times or in weather conditions that dramatically affect 

the UAS's flight (e.g. high winds) 

13. If an operation occurs in an area where people could inadvertently enter the area, an 

operational border will be established with traffic cones. If it's not feasible to use traffic 

cones due to interference with the photography/videography, the PIC's helper(s) will be 

responsible for keeping a safe perimeter around the operation. The operation will cease 

immediately and be rescheduled if it's impossible to establish a safe perimeter around 

the operation. 

14. The PIC will be responsible for logging all flights to ensure the comprehensive 

preventative maintenance plan can be followed, as described in the "Preventative 

Maintenance" section below. 

15. The SUAS will not be routinely operated in the proximity of any airports. In any cases 

where SUAS must be operated within three (3) miles of an airport, the airport operator 

will be notified before the operation commences. 

The operation of SUASs, weighing less than 7 Ibs., conducted in the strict conditions as outlined above, 

will provide an equivalent level of safety supporting the grant of exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled 

environment. As a result, they offer a much safer way to capture aerial photography and videography. 

Furthermore, the proposed operations represent a safety enhancement to the already safe operations 

that have been granted by the FAA for the establishment of the AMA National Model Aircraft Safety 

Code. 

Preflight Action Plan 

The PIC will follow a comprehensive pre-flight checl<list to ensure that the SUAS is in a condition for safe 

flight. This plan will be improved as needed in order to ensure all known safety precautions and/or 

safety precautions suggested by the manufacturer are being accounted for. 

A. Pre-flight Inspection 

1. Check that the remote control, Inspire 1 battery, range extender, and 

smartphone/tablet are all fully charged 

2. Verify that the Inspire 1 battery is not swollen or damaged in any way. Clean the 

contact needles and pads if necessary 

3. Turn the motor shafts with your fingers and verify they are smooth without excessive 

play or binding 

4. Verify that the propellers are mounted correctly. Each propeller should spin all the way 

down onto the motor shaft and safety clips installed after the propeller. 

5. Run finger along the edge of the propeller blade to check for any rough edges 
6. Flex both sides of the propellers' blades to check for hairline cracks where the blades 

connect in the center of the propeller 

7. Verify that the landing gear is secure (not cracked/broken/loose) 

8. Verify that the compass and compass cable is firmly attached to the landing gear 

9. Verify that the Micro-SD card has been inserted and formatted 

10. Verify that the damping absorbers are not broken and/or worn 

11. Verify that the anti-drop pins are in place and locked 

12. Remove the gimbal guard and camera lens cap 

13. Verify that the camera is secure and clean. Inspect the camera ribbon cables for tears 

and/or signs or wear 

14. Verify that the smartphone/tablet's GPS is enabled 

15. Set the smartphone/tablet to do-not-disturb mode to prevent distractions while flying 

16. Set the smartphone/tablet to forget any Wi-Fi networks in range in order to prevent the 

Wi-Fi connections from changing mid-flight 

17. Verify that the smartphone/tablet's audio is on to ensure the low battery warning and 

other alarms can be heard 

B. Power up 

1. Verify that S1 and S2 are in the center position on the remote control 

2. Power on the equipment 

i. SUAS battery (blinking green indicates GPS lock and ready to fly 

ii. Remote control (solid green and chime indicate lock on SUAS and ready to fly) 

3. Check the DJI Pilot app to ensure lock on 6+ satellites and home point is marked (for use 

by the failsafe feature) 

4. Calibrate the compass 

5. Place the Inspire 1 on open, flat ground with the battery indicators facing towards the 

PIC at least 10 feet away 

C. DJI Pilot App 

1. Connect the smartphone/tablet to the remote via USB 

2. Launch the app 

3. Verify the number of satellites is 6+ 

4. Verify signal strength 

5. Verify that the smartphone/tablet battery has a full charge 

6. Verify that both the PIC's and the Inspire 1's location is the same before taking off to 

ensure the home point has been accurately marked 

7. Verify the location of the Inspire 1 in the "flight radar." If it is not in the correct 

position/direction and/or shows a distance of "N/A", it did not mark the home point 

8. Use the "find my Inspire" feature to ensure the blue (home point location) and red 

(Inspire 1 location) dots are in the same location on the screen 

E~ 
D. Ready to fly 

1. Verify that the remote antenna is perpendicular to the ground (pointing skyward) 

2. Verify that the front, flat face of the range extender is pointed toward the Inspire 1 

3. Verify that the rear LED's are slowly blinking green and still connected to 6+ satellites 

4. Start the Inspire 1 motors using the remote control 

5. Verify the motors are functioning normally, and are not making any unusual noises, and 

are all spinning at the same speed 

6. Verify that the area is clear of obstructions, people, power lines, etc 

7. Take off and hover at about 6-8 feet above the takeoff point to verify that the Inspire 1 

has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc) land 

immediately and repeat the "Pre-flight inspection" and "power up" sequences 

8. Verify the Inspire 1 holds a steady position while yawing 360 degrees 

9. Verify the Inspire 1 responds appropriately to all controls-yaw left/right, pitch 

forward/backward, roll left/right, and throttle up/down 

Preventative Maintenance 

A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS's 

software is up-to-date, the batteries are in good health, and the aircraft itself is always ready for safe 

flight. 

Pilot in Command (PIC) Qualifications 

The PIC does not hold an airman certificate or medical certification. Since the SUAS is similar in size, 

weight, speed, and operating capability as those currently allowed to be flown for hobby/recreation, 

holding the PIC to those same set of standards will allow for an equivalent level of safety. 

The PIC has years of electronics and computer systems. Since the SUAS is controlled by a highly 

advanced computer system and runs on software that must be configured, updated, and maintained, 

computer proficiency is a must to ensure the SUAS is ready to be safely operated in the NAS. 

It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, 

has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, 

within strictly controlled pre-approved airspace. Since there are no standards for either private or 

commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and 

operation of the SUAS acquired from actual operation of the aircraft will be the most important factors 

in establishing an equivalent level of safety. With that in mind, Elevated Vue proposes that its PIC be 

required to do the following prior to the first commercial operation: 

Perform 20 flights or log 20 hours of flight time (the greater of the two) with the Inspire 1 

Successfully learn and demonstrate all flight maneuvers in the "Inspire 1 User Manuali 9 

3. Study and be familiar with all sections of "Inspire 1 User Manual" 

9http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf 

Ir] 
Public Interest 

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent level of 

safety, a reduction in environmental impacts, and are free from the harmful emissions associated with 

the manned aircraft that are currently used for aerial photography and videography. Due to the size of 

the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this 

application presents no risk to the public. Furthermore, the public will be able to legally acquire aerial 

photography and videography to help in, but not limited to, advertising homes for sale, advertising 

uninhabited home lots, use of photos and video as an aid when researching homes for sale on the 

market, or safely accessing high and/or awkward areas of a home's exterior to assess damage that 

needs to be repaired. 

Privacy 

Since the areas being photographed or filmed will be on private property, accessed only after given 

written and/or oral consent by the property owner(s), and clear of all people, except for the PIC and the 

PIC's helper(s), approval of this application presents no risk to public privacy. 

National Security 

Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will 

operate, approval of this application presents no risk to national security. 

Requested Exemptions 

Elevated Vue requests exemption from the following regulations since it's not possible to fully comply 

with them, and since attempting to follow them for the purposes of operating a SUAS would be a 

burden: 

Airworthiness Certificates 

14 CFR Part 21, Subpart H 

Subpart H establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR 91.203(a)(1). Given the size and limited operating area associated with the 

aircraft to be utilized by Elevated Vue, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 USC 44701(f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular SUAS. In all cases, an analysis of these criteria demonstrates 

that the SUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed, will be at least safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without the restrictions and conditions proposed. 

10 
Medical certificates 

14 CFR 61.23(a) 

This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks 

associated with the operation of the proposed SUAS are so diminished from the level of risk 

associated with any manned aircraft; the SUAS is of a size, weight, speed, and operational 

capabilities which make it much safer than any manned aircraft; since operations will occur in 

tightly controlled and limited airspace; and considering that all operations will be on private 

property that is clear of people, obtaining and maintaining a medical certificate would not 

improve the safety of the operation. In the very rare case of a mishap, the SUAS being flown will 

pose significantly less of a threat than manned helicopters and fixed wing aircraft because the 

SUASs re a fraction of the size and weight will be flown at a fraction of the speed, carry no 

flammable fuel, and carry no crew or passengers. 

Private pilot privileges and limitations: Pilot in command 

14 CFR 61.113(a) and (b) 

These regulations limit private pilots to non-commercial operations. Because the SUAS will not 

carry a pilot or passengers; due to the SUASs size, weight, speed, and operational capabilities; 

and since operations will occur in tightly controlled and limited airspace, the proposed 

operations can achieve the equivalent level of safety of current operations that require a 

commercial pilot's license. Furthermore, since there are no standards for either private or 

commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the 

control and operation of the SUAS acquired from actual operation of the aircraft will be the 

most important factors in establishing an equivalent level of safety. It cannot be assumed that a 

commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill 

or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, 

within strictly controlled pre-approved airspace. 

Flight instruction 

14 CFR 91.109 

This regulation provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

SUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. The equivalent level of safety provided by the fact that neither a pilot or passengers 

will be carried in the aircraft and by the size and speed of the aircraft. 

11 
Altimeter settings 

14 CFR 91.121 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set "...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the SUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator by confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

Fuel Requirements for Flight in VFR Conditions 

14 CFR 91.151(a) 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed —(1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the SUAS provides approximately 20 minutes of powered flight. That 

would it impossible to meet the 30 minute reserve requirement. Given the limitations on the 

SUAS's proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is reasonable. 

An equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery 

power (whichever occurs first). This restriction would be more than adequate to return the 

SUAS to its planned landing zone from anywhere in its limited operating area. 

Maintenance Inspections 

14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 

91.417(a) and (b) 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter...," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply. Maintenance will be accomplished by the operator pursuant to 

the aforementioned Inspire 1 user manual. An equivalent level of safety will be achieved 

because these small SUASs are very limited in size, will carry a small payload, and operate only 

in restricted areas for limited periods of time. If inechanical issues arise, the SUAS can land 

immediately and will be operating from no higher than 400 feet AGL. As outlined in the 

aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is in working 

order prior to initiating flight and perform maintenance as required. Moreover, the operator is 

12 
the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. 

In accordance with 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register: 

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR 

61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405(a); 14 CFR 

91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) and (b) to commercially 

operate small unmanned aircraft systems (55 Ibs. or less) in order to safely and legally capture 

aerial photography and videography for use by homeowners, realtors, home builders, home 

contractors, and/or home inspectors. 

The operation of SUASs conducted in the strict conditions outlined above, will provide an equivalent 

and/or greater level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and as a 

result, are far safer than existing operations conducted with helicopters operating in close proximity to 

the ground, people, or other buildings in the vicinity. 

Given the small size of the SUASs involved, the slow speed at which they must be operated in order to 

capture photos and videos, and the restricted environment within which they will operate, the Inspire 1 

demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned 

that the FAA must, by exemption, allow commercial operations of SUASs to commence immediately. 

Also, due to the size of the SUASs and the restricted areas in which the relevant SUASs will operate, 

approval of this application presents no threat to national security. Given the clear direction in Section 

333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level of 

safety surrounding the proposed operations, the significant public benefit — including enhanced safety, 

reduction in environmental impacts, no emissions, ability to legally obtain aerial photography and 

videography services —the grant of the requested exemptions is in the public interest. Accordingly, 

Elevated Vue respectfully requests that the FAA grant the requested exemption without delay. 

Satisfaction of the criteria provided in Section 333 of the Reform Act — size, weight, speed, operating 

capability, proximity to airports and populated areas, operation within the visual line of sight, public 

safety, and national security — provide more than adequate justification to grant Elevated Vue the 

requested exemption, allowing for commercial operations as described herewith. 

Sincerely 

; ~j~~✓~ 

Dan Jernigan 

Founder, Elevated Vue 

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